SUSTAINING AN ETHICAL CULTURE: IT S NOT ALWAYS BLACK AND WHITE

Transcription

1 SUSTAINING AN ETHICAL CULTURE: IT S NOT ALWAYS BLACK AND WHITE Most companies want to do the right thing when it comes to ethics. It seems that it should be as easy as telling everyone in the organization to always do the right thing. However, building an ethical culture is not that simple. The reality is that organizations are made up of people who have different experiences, biases, and views that shape their thinking. It s an ongoing dynamic challenge to keep each individual s values completely in line with the company s values. This session explores the dynamics of building and sustaining an ethical culture, especially in an environment where everything cannot always be black and white. BETHMARA KESSLER, CFE, CISA Chief Audit Executive Campbell Soup Company Bethmara Kessler is the Chief Audit Executive at the Campbell Soup Company and is on the ACFE Faculty and Advisory Council. Prior to joining Campbell s, Kessler served as the CAE and Co-Chief Compliance Officer at Warner Music Group. Her extensive experience includes leadership roles in audit, compliance, risk management, corporate investigations, business process improvement, and IT in a range of businesses including The Fraud and Risk Advisory Group, L Brands, EMI Group, Avon Products, Nabisco, and Ernst & Young. Kessler is a passionate fraud fighter and frequently speaks on a variety of topics related to fraud prevention and detection, investigations, auditing, compliance, and risk. She is a contributing author to the ACFE s Fraud Examiners Manual and Fraud Casebook: Lessons from the Bad Side of Business as well as several articles that have appeared in Internal Auditor Magazine, The Journal of Accountancy, and other specialty publications. Association of Certified Fraud Examiners, Certified Fraud Examiner, CFE, ACFE, and the ACFE Logo are trademarks owned by the Association of Certified Fraud Examiners, Inc. The contents of this paper may not be transmitted, republished, modified, reproduced, distributed, copied, or sold without the prior consent of the author. 2016

2 Why Are Ethical Decisions so Hard? Organizations are made up of people who have different experiences, biases, and views that shape their thinking. It s an ongoing dynamic challenge to keep each individual s values completely in line with the company s values. To further understand this challenge, try this experiment: Pick 25 random people from different generations, at different levels and in different roles in your business and ask them these questions: Is it okay for someone to take a few small office supplies home? Is it okay for people to check personal , Facebook, or Twitter accounts on company time? If you are out for a business dinner with a large group and your server takes really good care of you, is it reasonable to give them a 30 or 40 percent tip? What you re bound to find is that the answers to these questions won t always be clearly black and white, or easily answered yes or no. The variability of response and situational interpretation exponentially increases with the number of employees and geographic footprint of the company. Simply put, the people portion of values alignment is what makes building an effective ethics program challenge. Ultimately, the goal should be to continually shape a positive culture around ethics and compliance. Ten Tips to Continually Shape a Positive Culture Around Ethics and Compliance 1. Make It a Priority People must have a real belief that behaving ethically is an important value of their company

3 Treating the ethics program as a one and done or check the box compliance activity with episodic touchpoints that do the same things over and over won t work well. Be deliberate about finding ways to keep the tenants of an ethical culture visible in a way that is clear and shows employees that you really care. 2. Hire Ethical People It might sound obvious, but this is important. Work with your human resources partners to incorporate screening tactics that will help ensure that potential candidates are ethical. In addition to background checks and résumé verification, use the interview process to focus on how the candidate would handle ethical challenges and situational dilemmas. 3. Support Your Ethics Program with Great Policies A great policy is one that resonates with everyone in the business, regardless of who they are or where they sit. It needs to be relatable, and it should speak to people in the business unique language. Keep policies simple and make them easy to use. Don t bury people in detail or present something that reads like a legal textbook. Be as clear and transparent as possible, avoiding the pitfalls of leaving too much open to interpretation. Remember that policies don t need to be completely rules-based great policies should help people make good decisions. 4. Hold People Accountable for Complying with Policies Say what you will do and do what you say

4 If there are separate policies for people at different levels, be transparent with everyone about those differences. Otherwise, employees might perceive that you re not holding everyone accountable to the same standard. This will erode the ethical culture of the business over time. 5. Be Aware of the Glocal Impact on Your Program If your business has a global footprint, do your homework to understand laws, cultural practices, and other nuances that could derail your program s success. Tailor your program to the audience don't just translate what you use in your home country to local languages. Engage local folks to build and tailor the program to ensure it will resonate with local employees. 6. Engage People in a Way That Has Impact Be creative, and develop fun and engaging ways to bring the subject to life. Tell stories and cautionary tales in a way that will help shape people s thinking. Have your staff submit ideas to open up an ongoing dialogue and help solve ethical dilemmas or challenges. Use experiential learning techniques such as roleplaying and tabletop simulations to drive a deeper understanding of the company s values and expectations. Pilot new ideas to get real feedback that can improve the impact of the program

5 7. Open the Door Many businesses talk about having open-door policies, but sometimes those policies aren t available to the people who need them the most. Encourage open and honest communication to help employees ethically navigate the business. Don t shoot the messenger make it safe for people to feel good about coming forward if they know something or see something that doesn t seem to fall in line with the company's ethical values or standards. Actively publicize your hotline and encourage people to come forward. 8. Be Quick and Decisive The faster you act the more credible your business and its commitment to doing the right thing. Implement protocols for investigations that clearly define the accountabilities and processes that ensure a consistent and timely handling of issues. Make sure that people have a real belief and trust in the integrity of your investigative process, even if the outcomes are not always publicly visible and clear to all. 9. Create Teachable Moments When something bad happens, identify the root cause. Determine whether someone needs coaching, a process needs to be improved, or a policy needs to be rewritten. Fix the underlying issues, and in an appropriate way, use the lessons learned to teach others how to recognize or avoid similar situations in the future

6 10. Find Out How You re Doing Don t assume that all of your hard work is paying off. Always ask for suggestions for improvement. Does your organization think you re being authentic? Do people think you re speaking to them in ways they can relate? Do they believe that you say what you mean and mean what you say? Is your ethics program driving their thinking and changing behaviors? Your ethics program should be organic and always evolving